This Privacy Policy ("Policy") describes how Wolero Technology Pte Ltd ("WLT"), its parent company, respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively "WLT", "we", "us" or "our") collect, use, process and disclose your Personal Data through the use of WLT's apps and websites (including all mobile applications and websites operated by us, collectively "Platform"), products, features and other services globally (collectively, "Services").

This Policy applies to every user of our Platform, our customers, passengers, agents, vendors, suppliers, partners, contractors and service providers (collectively "you", "your" or "yours").

"Personal Data" is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, driving licence and vocational licence details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• Use our Platform
• Fill up a user profile or registration forms
• Provide information to assess your eligibility to provide services on our platform, for instance as a chauffeur
• Interact with our social media pages
• Participate in contests or events organised by us
• Use biometric features to identity yourself and
• Fill up demographic information in surveys.

Personal Data may be collected through the normal operation of our apps, websites, services and Platform. Some examples are:

• Your location, pickup and drop off timings and the route travelled while using our Services
• Feedback, ratings and compliments
• Transaction information (such as payment method and distance and time travelled)
• Information about how you interacted with our apps, website, services (such as features used and content viewed) and Platform
• Device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers) and
• Personal data you enter in messages when you use our in-app communication features.

When we collect Personal Data from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include but are not limited to:

• Referral programmes
• Our business partners, such as concierge service providers, payment providers and transport partners
• Publicly available data
• Governmental sources of data
• Marketing services providers or partners.

If you are a chauffeur on our Platform, we may collect:

• Telematics data (such as your speed, acceleration, and braking data)
• Distance and time driven, locations visited
• Device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device) and
• Your vehicle registration data.

Some of the information that we may collect is sensitive in nature. This includes information such as national ID numbers, race, marital status, and your health or religious beliefs. We only collect this information when this is strictly necessary to comply with legal or regulatory requirements.

Some chauffeurs on our Platform may install personal in-vehicle cameras in their vehicles for their own purposes (including safety and security). The use of such in-vehicle cameras is not encouraged, endorsed or prohibited by WLT. The collection, use and disclosure of Personal Data obtained from personal in-vehicle cameras is the responsibility of the relevant chauffeur. Please check with the relevant chauffeur if you have any queries about their use of personal in-vehicle cameras.

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to us. In the event that such Personal Data of a minor is disclosed to us, you hereby consent to the processing of the minor's Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may facilitate them using our Platform. If you provide us with their Personal Data, you represent and warrant that you have and you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.

We may use, combine and process your Personal Data for the following purposes ("Purposes").

Your Personal Data will be used to provide, personalise, maintain and improve our products and services. This includes using your Personal Data to:

• Provide you with Services across our various business verticals
• Engage you to provide Services
• Create, administer and update your account
• Verify your identity
• Validate your ride or journey and process payments
• Track the progress of your trip and detect abnormal trip variations
• Enable features that personalise your App, such as lists of your favourite places and previous destinations
• Perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends
• Protect the security or integrity of the Services and any facilities or equipment used to make the Services available
• Process and manage your rewards
• Enable communications between users of our Platform
• Process, manage or verify your application for membership with WLT and to provide you with members benefits and
• Enable our partners to manage and allocate fleet resources.

We use your data to ensure and improve the safety and security of our services and all users. This includes:

• Screening chauffeurs before enabling their use of our Services
• Identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to chauffeurs
• Verifying your identity when you log in to our Platform
• Using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities
• Sharing chauffeurs and passengers' location and details when the emergency button
• Monitoring compliance with our terms and conditions, policies and chauffeurs Code of Conduct and
• Detecting, preventing and prosecuting crime.

We use Personal Data to resolve customer support issues. For example, we may:

• Investigate and address concerns
• Monitor and improve our customer support responses
• Respond to questions, comments and feedback and
• Inform you about steps taken to resolve customer support issues.

We may use the Personal Data we collect for testing, research, analysis and product development. This helps us to understand and analyse your preferences and needs, protect your personal data, improve and enhance the safety and security of our services, and develop new features, products and services.

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable laws.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• Comply with court orders or other legal, governmental or regulatory requirements
• Enforce our Terms of Use or other agreements and
• Protect our rights or property in the event of a claim or dispute.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

We may use your Personal Data to market Li-nk, WLT and our partners' sponsors and advertisers' products, services, events or promotions. For example, we may:

• Send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings and
• Notify, invite and manage your participation in our events or activities

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our app settings or websites.

We need to share Personal Data with various parties for the Purposes. These parties include:

• Other users

  For example, if you are a passenger, we may share your pick-up and drop-off locations with chauffeurs. If you are a chauffeur, we may share your Personal Data with your passenger including your name and photo; your vehicle brand, model, number plate, location and average rating.

• With third-parties

  For example, we may share a chauffeurs location and name with third parties when a passenger activates the Emergency Button.

• With WLT partners at your request

  For example, if you requested a service through a WLT partner or used a promotion provided by one of our partners, we may share your Personal Data with that partners. Our partners include partners that integrate with our app or website or our app or website integrates with, vehicle services partners, or business partners which we collaborate with to deliver a promotion, competition or other specialised service.

• With the owner of the accounts on our Platform that you may use

  For example, your company or employer may receive trip data when you may use their corporate Li-nk or WLT account.

• With parent companies, subsidiaries and affiliates

  We share Personal Data with our parent companies, subsidiaries, associated companies, jointly controlled entities and affiliates.

• With our service providers and business partners

  We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

  • Payment processors and facilitators
  • Background check and anti-money laundering service providers
  • Cloud storage providers
  • Marketing partners and marketing platform providers
  • Data analytics providers
  • Research partners, including those performing surveys or research projects in partnership with us or on our behalf
  • Fleet and merchant partners and
  • Vehicle solutions partners, vendors or third-party vehicle suppliers.
• With our legal advisors and governmental authorities

  We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties.

We retain your Personal Data for as long you maintain your account with us. Once your Personal Data is no longer necessary for the Services or other purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to prevent access or use of such Personal Data for any purpose other than compliance with this privacy policy, or for purposes of safety, security, fraud prevention and detection.

Your Personal Data may be transferred from the country, state and city ("Home Country") in which you are present while using our services to another country, state and city ("Alternate Country"). You understand and consent to the transfer and possible storage of your Personal Data from your Home Country to the Alternate Country.

WLT and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash, advertising identifiers (including mobile identifiers such as Apple's IDFA or Google's Advertising ID) and similar technology ("Cookies") in connection with your use of our Apps, Websites, Services and Platform. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

We may allow third parties to use Cookies on our apps, websites and Platform to collect the same type of Personal Data for the same purposes as WLT does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

If you do not wish for your Personal Data to be collected via Cookies on our websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this Personal Data through your mobile device settings.

We shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on our apps, websites and Platform. By continuing to use the apps, websites, Services or Platform, continuing to communicate or engage with us following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

If you have any queries about your personal data, please contact our Data Privacy Officer at:

Wolero Technology Pte Ltd
Attn. PDPA Officer
65 Airport Boulevard B1-36A
Singapore 819663
Email: feedback@wolerotechnology.com

In the event of any conflict between the English version and other language of this Policy, the English version prevails.